AML & KYC Policy

1. Purpose and scope

This is the player-facing summary of our anti-money-laundering and counter-terrorist-financing programme. It explains what we check, when we check it, and what happens if something does not add up. The full internal programme — risk assessment, procedures, training records, reporting lines — is held separately and is available to a regulator on request.

2. A risk-based approach

Checks are proportionate to risk. Most players see identity verification once, before their first withdrawal, and nothing else. Risk is scored from country, deposit and withdrawal behaviour, account age, source of funds and the on-chain history of the addresses involved; a higher score means more evidence, not an automatic refusal.

3. Identity verification

We do not ask for documents at registration — you can sign up and play without friction. Verification is required:

• before your first withdrawal;
• when cumulative volume crosses a tier threshold;
• when a monitoring rule or a sanctions check calls for it;
• at any time we have reasonable grounds to doubt information you have given us.

Basic

Email, phone, government identity document and a liveness selfie. Withdrawal ceiling of about $10,000 a month.

Full

Basic plus proof of address and evidence of source of funds. Ceiling of about $200,000 a month.

Enhanced

Full plus manual review by a compliance officer. Applied to high-risk profiles and politically exposed persons; ceiling set case by case.

Verification is carried out by a specialist provider. Your documents are collected and stored by them; we receive and store the result, not the paperwork.

4. Source of funds and source of wealth

Where volume, risk score or a monitoring rule requires it, we ask how the money you are playing with was acquired. Payslips, tax returns, sale agreements, exchange statements and similar evidence are acceptable. We ask for the minimum that answers the question, and we tell you why we are asking unless the law forbids it. An account may be restricted to withdrawals only until the question is answered.

5. Sanctions, PEP and address screening

• Every player is screened against sanctions, terrorism and politically-exposed-person lists at registration and re-screened as the lists change.
• Every deposit and withdrawal address is screened for links to sanctioned entities, mixers, darknet markets and known theft.
• Addresses are scored 0–100. Up to 25 clears automatically; 26–60 goes to manual review; 61–80 goes to manual review with additional verification; above 80 is refused and the account is frozen pending investigation.

6. Transaction monitoring

Deposits, wagers and withdrawals are monitored continuously. Among the patterns that route a withdrawal to review:

• cumulative withdrawals above $5,000 in 24 hours;
• withdrawals to more than three distinct addresses in 24 hours;
• a first-ever-seen destination address for an amount above $1,000;
• a withdrawal from a country different to the one you signed in from in the last day;
• an account less than seven days old withdrawing more than $500;
• a sign-in from a new device followed by a withdrawal within the hour;
• depositing and withdrawing with little or no play in between.

Flagged withdrawals go to a review queue regardless of any auto-approval setting, and large ones require two separate people to approve. Review is a delay, not a refusal — most flags clear the same day.

7. Suspicious activity reporting

Where we have knowledge or suspicion of money laundering or terrorist financing, the Money Laundering Reporting Officer files a report with the relevant financial intelligence unit. The law prohibits us from telling you that a report has been made, and it may require us to freeze funds or continue a relationship while an investigation proceeds. We will never mislead you about the reason for a delay; we may simply be unable to give one.

8. Prohibited use

• Depositing and withdrawing without a genuine intention to play.
• Playing on behalf of another person, or funding an account from someone else’s wallet.
• Using the platform to convert, layer or move funds of criminal origin.
• Structuring deposits or withdrawals to stay under a threshold.
• Accessing the service from an excluded or sanctioned jurisdiction, including by VPN or proxy.

Any of these ends the relationship, and where the law requires it, is reported.

9. Records and governance

• Verification results, screening outcomes, transaction records and reviewer decisions are retained for at least five years after the account closes.
• Every administrative action is written to an append-only audit log with the actor, the reason and the time. Corrections are new entries; nothing is edited or deleted.
• Staff with access to compliance functions are trained on appointment and at least annually, and their access is role-based and two-factor gated.
• The programme is reviewed at least once a year and after any material change to the product or the licence.

10. Contact

Compliance correspondence: compliance@softico.app. Verification questions are handled by support and escalated where necessary; please do not send identity documents by email — always use the secure verification flow in your account.